Transformation Roundtable Discussion with CBOs and Representatives

As a part of its ongoing public outreach efforts, USCIS recently hosted two roundtable discussions in Washington, D.C. to obtain feedback about upcoming changes to the Agency’s business processes.

The September 25 Transformation Roundtable Discussion involved direct feedback from a group of Community Based Organizations (CBOs) and customer representatives regarding the development of electronic accounts. Ultimately, these accounts will form the basis for USCIS Transformation, which is a multi-year effort to create a more transparent, effective, and customer-focused organization.

The following is a summary of this meeting. USCIS plans to host more of these sessions in the future and will post details for those interested in participating as meetings are scheduled.

Executive Summary of Feedback

USCIS should use online environment to better exchange information with other agencies

Online channels should ease customers’ ability to receive time sensitive information from USCIS

Account setup and electronic filing should speed up adjudication of cases

Participants want the ability to print certain notices from USCIS such as approval notices

For online channels to be successful, USCIS should make them easier to use than what is currently available (e.g., customers should be able to scan in documents and submit electronically)

USCIS should carefully consider how third party access will be provided; there may need to be different levels of access to different entities (e.g., employers, beneficiaries or attorneys)

Online account setup and electronic filing should be extremely secure to account for privacy and identity theft concerns

Certain segments of the immigrant population may have limited access to internet, e-mail, kiosks, or scanners; similarly, some populations may have difficulty using these channels even if they are accessible

Introduction

Greg Collett, Chief, Office of Transformation Coordination, explained that USCIS is redesigning its business through a Transformation program led by business processes enabled by technology. Mr. Collett provided an overview of Transformation, comparing “the Current State” to proposed concepts for how interaction with USCIS could look in the future as depicted below:

Customers or representatives will have online self-service options to update some information (e.g. address or contact information)

Topic 1: Access to Online Channels

Question #1: Do the benefit seekers you work with have access to the Internet and e-mail? What about representatives or organizations that help prepare applications for benefit seekers?

Summary of Responses

Every member of ACIP has e-mail and online access

Online accounts should be extremely easy to set up if USCIS wants to encourage their use

Not all individuals have regular access to the internet (e.g., students travelling from developing countries)

Some benefit seekers would need significant assistance using online channels even if access was made available through public means (e.g., public libraries)

There is a concern that people who have already filed an application on paper would be subject to longer processing times or would not be able to check status via an online account (especially if his/her case was filed before 2001 at a district office and they were not provided with a receipt number).

There must be a way to ensure that a person’s information is not left on a machine –ensure logout of system so residual information is not left behind (for example if a person accesses his account and files something online using library computer)

Question #2: What’s your perception of whether benefit seekers have ever used a kiosk? (Example: ticketing kiosks at an airport)

Summary of Responses

USCIS should look at “lessons learned” from CBP kiosk usage

USCIS should consider putting kiosks in public locations (e.g., libraries or malls) and should be careful not to put them in secure buildings where people will need an Infopass appointment to get inside

If kiosks are a viable solution, they should be well-maintained, reliable and have multiple language capabilities

If kiosks are located in a library or public place, concerns may be raised about privacy as individuals may need sensitive documents to file applications via a kiosk

Kiosks might be most appropriate for checking status, or other “simple” tasks; some types of applications are very time consuming and usually people don’t have all of the documentation with them – these might be too complex for kiosks to be used efficiently

USCIS should make sure the public knows how to use kiosks and that they are free for use

USCIS may wish to provide assistance at kiosks for populations who may be unfamiliar with new technology (e.g., elderly). Account for the potential that kiosks may have long lines to use them

If kiosks will be a primary channel for exchanging electronic information with USCIS, the Agency should account for the potential that kiosks could develop long lines of customers

Password access to kiosks may pose security or concerns if benefit applicants forget passwords or lose written documents with passwords included

Question #3: Do the benefit seekers you work with have access to high-resolution scanners? What about representatives or organizations that help prepare applications for benefit seekers?

Summary of Responses

All ACIP members have ready access to scanners at all times and are familiar with their use

Most members of AILA and NAFSA, and some CBOs, have access to more sophisticated technologies like scanners and have the ability to scan documents; some CBOs, however, do not have scanners and lack the financial capacity to update technology on a regular basis

If people are going to be able to file applications at kiosks, scanners should also be available at those locations

USCIS should maintain current paper-based system for applicants who may not be familiar with new technology (e.g., elderly)

Topic 2: Benefits, Preferences, and Considerations in Doing Business Online with USCIS

Question #1: If you could communicate with USCIS online, what would you want to be able to do?

Summary of Responses

Participants would like USCIS to share information with other government agencies; USCIS should heavily involve federal stakeholders in any plans to create an online system for exchanging immigration information

SEVIS II is developing customer accounts; if someone already has a SEVIS account, it would be good if that person could have the information from that account transferred into the USCIS system

If customers have accounts with other agencies (e.g., DOL iCert account) then one should be able to import the information into USCIS systems; this would save USCIS some resources since DOL would have already done “bone fides” investigation of the information provided

Participants expressed interest in submitting applications online and engaging with USCIS while the application is pending to receive meaningful case status updates

Case status information online should be posted in real time or close to it

USCIS should provide some capability for troubleshooting

If benefit applicants can check their case status online, the online status should show what was done as well as “next steps”

Participants would like for USCIS to make it easier for time sensitive information to reach them in a more timely manner

If a request for evidence (RFE) or NOID (Notice of Intent to Deny) is issued, benefit seekers and representatives should have to provide them electronically so that there is as much time as possible to respond

Online communications should increase the speed of USCIS’ processing of cases; if responses to requests for evidence, etc. can be filed online, then adjudication times should improve

Question #2: What concerns do you have about doing business with USCIS online?

Summary of Responses

Sometimes representatives’ only proof of filing is an actual paper copy of the application as filed, or a Federal Express confirmation of delivery.

Question #3: What do you think about the potential for mandatory e-filing?

Summary of Responses

Employment-based applications or others such as replacement of lost I-94 card (Form I-102) or Form I-824 (Action on approved petition) may be easier to e-file; It would be easier for employment based applications to be e-filed

Participants suggested other forms for e-filing related to the employment-based fifth preference (i.e. Form I-526-Petition by Alien Entrepreneur and Form I-829 Petition to Remove Conditions)

USCIS should improve current state of e-filing before mandating

USCIS should create ways for customers or representatives to link supporting documents with e-filed applications

E-filing is a nice alternative, but it should be an alternative rather than a requirement

Question #4: How could USCIS could incentivize the setup of online accounts and electronic exchanges of information for benefit seekers or representatives?

Summary of Responses

Online accounts should offer: time savings; quicker processing times; more meaningful case status updates provided; and delivery of electronic status in real time at key points in the application process

E-filing systems should interact with existing off-the-shelf case management software systems used by many attorneys

Electronic system interfaces with other agencies such as DOL

USCIS should consider reduced filing fees for applications that are e-filed

USCIS could provide interim work authorization for those who apply for extension of employment authorization document online

Topic 3: Data Collection for Account Set-up

Question #1: What do you think about the data elements USCIS is suggesting it may request from different parties to establish online accounts?

Summary of Responses

Information provided for representative account is same as on G-28

USCIS should be collecting physical address from each person setting up an account

Some benefit seekers may be from the same place and have the same name; USCIS should consider an additional unique identifier for account setup (maybe Alien number for persons already in system)

Topic 4: Third Party Access to Accounts

Question #1: How much information should representatives be allowed to view about a benefit seeker’s account? (Example: entire application history or only applications filed by that representative)

Summary of Responses

Employers will want the flexibility to determine who will receive notices/have access if employer is filing application on behalf of beneficiary- sometimes employer will want notice, sometimes will want benefit seeker to have it, sometimes just attorney, etc.

Once an individual is recognized as a representative or attorney, he/she should be able to have access to client’s whole file (as if you had filed a FOIA request)

USCIS should consider asking for authorization to file on behalf of someone online; for example, when an attorney files a PERM application on behalf of an employer (like with DOL), the DOL asks employer if it authorized application

USCIS should allow owner of an account to enlarge or limit the access available to third parties; For example, allowing employers to limit an employee’s access to certain information on form I-140 (such as gross income of company)

Access to USCIS information needs to be limited so that abusers or human traffickers are unable to find out about filings or obtain status information

Some persons may not want anyone aside from their representative to have access to benefit or account information

Some benefit seekers may not want others in their immediate family to have access to see what has been filed, even if they are in the same family; for example, youth applications for asylum

Sometimes sponsors (such as for marriage-based green card) do not want the beneficiary to see financial information provided to USCIS on their behalf